SEC Comment Letter 0000000000-24-007727 to MITSUBISHI UFJ FINANCIAL GROUP INC (MUFG)
MITSUBISHI UFJ FINANCIAL GROUP INC
Date: July 9, 2024 · CIK: 0000067088 · Accession: 0000000000-24-007727
AI Filing Summary & Sentiment
File numbers found in text: 000-54189
Letter
July 9, 2024 Tetsuya Yonehana Chief Financial Officer Mitsubishi UFJ Financial Group, Inc. 7-1, Marunouchi 2-chome Chiyoda-ku, Tokyo 100-8330 Re:Mitsubishi UFJ Financial Group, Inc. Form 20-F for the Fiscal Year Ended March 31, 2023 Response Dated March 5, 2024 File No. 000-54189 Dear Tetsuya Yonehana: We have reviewed your March 5, 2024 response to our comment letter and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our February 21, 2024 letter. Form 20-F for the Fiscal Year Ended March 31, 2023 Note 2. Business Developments - Sale of MUFG Union Bank, page F-26 1.Please refer to prior comment 2. We have considered the information provided in your response and a call on April 24, 2024. We object to your policy characterized as “the elimination of the differences in reporting periods” in which you directly adjusted shareholders’ equity and the August 31, 2022, carrying value of MUFG Union Bank’s assets and liabilities in order to reflect MUFG Union Bank’s financial results for the three months ending November 30, 2022 for both the transferred and sold assets and liabilities. Please restate your financial statements and related disclosures or tell us why a restatement is not required.
July 9, 2024 Page 2 Please contact Ben Phippen at 202-551-3697 or Michael Volley at 202-551-3437 if you have questions. Sincerely, Division of Corporation Finance Office of Finance
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July 9, 2024
Tetsuya Yonehana
Chief Financial Officer
Mitsubishi UFJ Financial Group, Inc.
7-1, Marunouchi 2-chome
Chiyoda-ku, Tokyo 100-8330
Re:Mitsubishi UFJ Financial Group, Inc.
Form 20-F for the Fiscal Year Ended March 31, 2023
Response Dated March 5, 2024
File No. 000-54189
Dear Tetsuya Yonehana:
We have reviewed your March 5, 2024 response to our comment letter and have the
following comment.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless we
note otherwise, any references to prior comments are to comments in our February 21, 2024
letter.
Form 20-F for the Fiscal Year Ended March 31, 2023
Note 2. Business Developments - Sale of MUFG Union Bank, page F-26
1.Please refer to prior comment 2. We have considered the information provided in your
response and a call on April 24, 2024. We object to your policy characterized as “the
elimination of the differences in reporting periods” in which you directly adjusted
shareholders’ equity and the August 31, 2022, carrying value of MUFG Union Bank’s
assets and liabilities in order to reflect MUFG Union Bank’s financial results for the three
months ending November 30, 2022 for both the transferred and sold assets and liabilities.
Please restate your financial statements and related disclosures or tell us why a
restatement is not required.
July 9, 2024
Page 2
Please contact Ben Phippen at 202-551-3697 or Michael Volley at 202-551-3437 if you
have questions.
Sincerely,
Division of Corporation Finance
Office of Finance